Privacy Policy

KingsIsle Privacy StatementLast Updated: July 19, 2018

Please take the time to read this notice carefully

SCOPE AND YOUR AUTHORIZATION

This Privacy Statement ("Privacy Statement") applies to KingsIsle Entertainment, Inc. ("KingsIsle," "we," "us," or "our") websites, online games (such as Wizard101 and Pirate101), communications, advertisements, and other online services and resources that collect data and display or link to this Privacy Statement (collectively, "Online Games and Services"). This Privacy Statement does not apply to websites, games, products, services or other environments that do not display or link to this Privacy Statement or that have their own privacy policies, or information collected from you offline.

We developed this Privacy Statement in order to be transparent about the data we collect about you and how it is used and shared, as well as the choices and rights available to you with respect to the data we maintain about you.

Our Online Games and Services are operated by KingsIsle in the United States and any personal data submitted through our Online Games and Services will result in the collection and processing of such information in the United States. As a result, if you are visiting or using our Online Games and Services from a country other than the United States, your personal data will cross an international boundary. The level of protection for your personal data in the United States may not be the same as the level of protection in your country.

Please be sure to read this Privacy Statement before using our Online Games and Services or submitting information to us. Our Privacy Statement may change from time to time and your continued use of our Online Games and Services constitutes acceptance of such changes, so please check this area periodically for updates to this Privacy Statement.

If you reside in Europe, you must be at least 16 years old to use our Online Games and Services.

HOW YOU CAN CONTACT KINGSISLE

KingsIsle is based in Texas, United States, and develops and publishes high quality online games that appeal to a wide audience. We are responsible for and control the information collected from or about you in connection with our Online Games and Services subject to this Privacy Statement. You can contact us at any time if you have any questions:

KingsIsle collects information that can be used to identify or contact a particular person (we refer to this type of data as "personal data"). Personal data may also include information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our Online Games and Services and which if combined with certain other information could be used to identify you.

The information we collect includes information you actively provide to us through our Online Games and Services, certain information collected passively through your use of our Online Games and Services, and information collected from other third-party sources. In addition, we may allow select third-party partners to passively collect certain information from you through your use of our Online Games and Services.

PLEASE NOTE: You may have a separate account for each Online Game and Service that you register for, or you may be able to use a single account across all of our Online Games and Services. In either case, this Privacy Statement applies to your use of our Online Games and Services and each separate environment or component thereof.

Active Information Collection

Much of the personal data we collect from our visitors and players is submitted by visitors/players in response to our requests, such as during the registration process, or in response to polls, forums, promotional offers or other interactivity incorporated into our Online Games and Services. From time-to-time, visitors and players may also submit personal data directly to us via e-mail. The information we actively collect may include some or all of the following:

Name

Address (including City, State, Country and/or Zip Code)

E-Mail address

Username

Password

Gender

Poll and survey responses

Promotional offers you select

Information regarding your computer hardware and network connectivity

We collect, use, store, organize, structure, disclose, or otherwise process this personal data for the following purposes:

We process personal data for the purposes for which such personal data was provided. For example, if you share your name and contact information with us when submitting an inquiry or registering to play one of our games, we will use this information to respond to you or provide you with access to the relevant game and manage your account with us. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), and provide customer support.

To engage in direct marketing activities, including to personalize your experience on our Online Games and Services and to deliver content and product offerings relevant to your interests, including targeted offers and ads through our Online Games and Services, third-party websites and games, and via email or text message. The relevant legal basis under European law (where applicable) is our legitimate interest to improve your experience while using our Online Games and Services, promote our products and services, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

To send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with KingsIsle, you generally may not opt out of receiving these communications. The relevant legal basis under European law (where applicable) is our legitimate interest to provide customer support and keep visitors/players information of our practices and terms. In specific circumstances, we may need to engage in these activities in order to comply with an applicable law. Where we process your personal data to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations.

To help maintain the safety, security, and integrity of our Online Games and Services, products, databases, and other technology assets. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services and to provide, manage and optimize our products and services (including our Online Games and Services).

For internal administrative purposes, such as auditing, data analysis, and research to improve our products, services, and customer communications. This includes processing for purposes of statistical analysis. The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, develop new products and services, and better understand users and their preferences.

Where we have legal obligations to process the personal data and for legal proceedings and government investigations (such as pursuant to warrants, subpoenas, and court legal orders).

In addition, we may require you to submit billing information to pay any fees applicable to participation in our Online Games and Services. Depending on the type of payment method, this billing information may include credit card or comparable payment account number, billing address, name on card/account, expiration date and security code. We use this information for purposes of processing your payment and providing you with the Online Games and Services purchased. The relevant legal basis under European law (where applicable) is our legitimate interest to fulfill our obligations under a contract to which you are subject.

Passive Information Collection

As you navigate through our Online Games and Services, other information that does not, on its own, identify any particular individual may be collected. This information includes:

Log data. When you use or interact with our Online Games and Services, our servers record certain information that is automatically reported by your browser (such as Apple's Safari, Microsoft's Edge, Google's Chrome, or Mozilla's Firefox) or device each time you request our Online Games and Services, or when content is downloaded to your browser from our Online Games and Services. This "log data" includes your IP address (which is used to infer approximate location); Internet service provider; browser type and settings (for example, content language, cookie/DNT preferences); device information (for example, type of device, operating system, device manufacturer); referring/exiting URL; request/response date and time; "clickstream" data which reflects activities on our Online Games and Services such as the features you visit and in what order; device ID or advertising ID; and data contained in cookies and similar technologies (discussed below). However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data.

Location data. Depending on the Online Games and Services and your computer or device permissions, we may collect information about your device's approximate (for example, country or zip code) or precise location ("location data"). Various technologies may be used to collect this location information, such as IP address, GPS, and other sensors that may provide information on nearby devices, Wi-Fi access points, and cell towers. We will only collect your computer's or device's precise location with your consent.

Cookie data. Our Online Games and Services also use technologies which are common among websites and online environments to collect and store certain information (such as log data or unique identifiers) when you visit or interact with our Online Games and Services. These technologies include cookies, Web beacons (also known as pixel tags or clear GIFs), statistical identifiers, and similar technologies. A "cookie" is a unique numeric code that is transferred to your computer or device to track your interests and preferences and to recognize you as a return visitor. A "Web beacon" is a transparent graphic image placed on a website that enables the monitoring of things such as user activity and site traffic. "Statistical identifiers" refer to identifiers created using certain device information and identifiers that makes your browser or device sufficiently distinct for a server or similar system to reasonably determine that it is encountering the same browser or device over time.

Our Online Games and Services use cookies and similar technologies to help us secure our Online Games and Services, as well as the information processed by our Online Games and Services; to monitor and enhance the performance of our Online Games and Services; to remember your preferences on our Online Games and Services; to collect "clickstream" data which reflects activities on our Online Games and Services such as the features you visit and in what order; to better understand visitor and user behavior; and to facilitate and measure the effectiveness of advertisements and website features.

The relevant legal basis under European law (where applicable) is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), improve your experience while using our Online Games and Services, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

We may tie personal data actively collected from you to information collected passively as described above or from third parties. In such cases, if we associate non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined.

Do Not Track

Some web browsers may transmit "do-not-track" signals to websites with which the browser communicates. The webserver for our Online Games and Services does not currently respond to these signals.

Use of Cookies and Similar Technologies by Our Online Partners

We may use vendors and other online partners to perform some of the activities described above, including to provide audience measurement and analytics services, to serve ads on our behalf on our Online Games and Services and on third-party sites, and to track and report on the performance of such ads. These online partners may use cookies and similar technologies to collect and store certain log data, location data, cookie data and other information when you visit or interact with our Online Games and Services and other unaffiliated sites in order to identify your browser or device and provide their respective services. Further, these online partners may combine data collected on our Online Games and Services with information collected on unaffiliated sites or with any other data maintained by these online partners. Their use of data collected on our Online Games and Services and third-party sites will be subject to their own terms of use and privacy policies.

For example, we may use third-party cookies to deliver our ads on third-party websites through a common form of online advertising known as "retargeting." Retargeting works by serving ads on one website based on an individual's activities on a different website. To do this, we allow our online partners (such as Google or other ad network vendors) to serve their own third-party cookies when users visit our Online Games and Services, allowing these online partners to recognize users who have previously visited our Online Games and Services. When these users visit a third-party website that includes features provided by our online partners (for example, where our online partners have purchased ad space), our online partners can recognize the users' interest in our products and services and deliver one of our ads on the third-party website.

Your Cookie Choices

Most browsers are set to accept cookies by default. However, browsers typically allow individuals to remove or block browser cookies if they choose. For more information on blocking and removing browser cookies, please review your browser's Settings or Preferences tab. More information can be found here:

For other browsers, please consult the documentation that your browser manufacturer provides.

In addition to removing and blocking browser cookies generally, the following opt-out mechanisms may be available if our Online Games and Services utilize the third-party cookies listed below:

Google Analytics. Our Online Games and Services may use Google Analytics, a web analytics service provided by Google. Google Analytics utilizes cookies and similar technologies to collect and analyze information about the performance and use of our Online Games and Services. More information on Google Analytics can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google Analytics opt-out available here.

Google Retargeting. Our Online Games and Services may use Google's Remarketing with Google Analytics to allow Google to use information about your visits to our Online Games and Services and other unaffiliated websites in order to measure advertising effectiveness and serve ads about our products and services that may be of interest to you. As described above, Google places its own cookies when users visit our Online Games and Services which enable Google to recognize users who have previously visited our Online Games and Services when such users visit other unaffiliated sites that also use Google's services and cookies. More information on Google's Remarketing with Google Analytics can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google Analytics opt-out available here.

Google DoubleClick. Our Online Games and Services may use Google DoubleClick to deliver ads based on user preferences. More information on Google DoubleClick can be found here. If you would like to opt-out of having your information collected and used as described, please use the Google opt-out available here.

Facebook Custom Audiences. Our Online Games and Services may use Facebook Custom Audiences to deliver ads on Facebook about our products and services that may be of interest to you. More information on Facebook Custom Audiences can be found here. If you would like to opt-out of having your information collected and used as described, please use the opt-out available here.

Interest Based Advertising. Our Online Games and Services may use cookies and similar technologies for targeted advertising based on user interests, demographics, and past browsing activity. If you would like to opt-out of having your information collected and used by us for these purposes, please visit:

The list above identifies some of the third-party cookies we may use on our Online Games and Services. However, we may use other third-party cookies and similar technologies on our Online Games and Services that are not listed here. This list is subject to change at any time and without notice.

BY CONTINUING TO USE OUR ONLINE GAMES AND SERVICES, YOU CONSENT TO THE USE OF COOKIES AND SIMILAR TECHNOLOGIES AS DESCRIBED IN THIS PRIVACY STATEMENT.

INTERACTION WITH SIGN-IN SERVICES AND SOCIAL MEDIA ACCOUNTS

From time-to-time, our Online Games and Services may allow you to log in using sign-in services such as Facebook Connect, Apple’s Game Center, or an Open ID provider. These services will authenticate your identity and may provide you the option to share certain personal data with us such as your name, email address, and resume to pre-populate our sign up form. Once your identity has been authenticated, we may collect certain information such as the sign-in service used and a unique identification code associated with the sign-on service.

From time-to-time, our Online Games and Services may also contain functionality which enables you to import profile information or contacts from third party services (e.g., LinkedIn, Facebook, Twitter, Gmail, FourSquare, Instagram, Vine, etc.) (collectively, "Third Party Social Media Accounts"). If you choose to do this, you may have to log into the applicable Third Party Social Media Account, using such account’s user name and password. The copy of the information received by us shall be subject to this Privacy Statement. However, any data maintained by such third party service and your use of that third party service will be subject to that third party’s terms of use and privacy policy. You may have the ability to post information from our Online Games and Services to your Third Party Social Media Accounts (including, without limitation, by taking advantages of features such as the Facebook "like" button appearing on our Online Games and Services). All such postings are also subject to the terms of use and privacy policy of the applicable third parties as well as the terms of this Privacy Statement.

The relevant legal basis under European law (where applicable) when processing your personal data for these purposes is our legitimate interest to guarantee the stability and security of our Online Games and Services, provide, manage and optimize our products and services (including our Online Games and Services), improve your experience while using our Online Games and Services, promote our products and services, provide customer support, develop new products and services, better understand users and their preferences, and measure and manage the frequency of our ads.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We will not sell or otherwise disclose personal data about you, except as described here.

Service Providers. In the course of doing business, we employ other companies and individuals to perform a variety of functions on our behalf. For example, we may provide your information to companies that host our Online Games and Services or process credit card information. These service providers may have access to personal data about you if it is needed to perform their functions for us, but they are not authorized by KingsIsle to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.

Social Media. As discussed in the "Interaction with Sign-In Services and Social Media Accounts" section above, you may have the ability to share information from our Online Games and Services to your Third Party Social Media Accounts. Online Games and Services that allow you to do this use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with others. When you visit our Online Games and Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Online Games and Services. If you are logged into the Third Party Social Media Account (e.g., Facebook) while browsing on our Online Games and Services, the social plugins allow that social media websites to receive information that you have visited our Online Games and Services. The social plugins also allow the social media website to share information about your activities on our Online Games and Services with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our Online Games and Services to your Facebook friends.

Online Partners. Please see the " Use of Cookies and Similar Technologies by Our Online Partners" section above.

Legally Required. We reserve the right to disclose information if required to do so by law or by a regulatory authority. We may also disclose your information as part of an investigation or enforcement action relating to improper or illegal conduct in connection with our Online Games and Services, including, without limitation, any situations that may potentially involve threats to the safety or privacy of any person, misuse of Online Games and Services or violation of our Terms of Use.

Sale or Bankruptcy. During the normal course of our business, KingsIsle may sell or purchase assets. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through our Online Games and Services in a manner that is consistent with this Privacy Statement.

Aggregated and Non-Personal Data. KingsIsle may maintain aggregate data or other non-personal data about you, such as usage statistics, online traffic patterns and user feedback. In addition to using this information for the purposes discussed above, KingsIsle may disclose this information to third parties without restriction.

SPECIAL NOTE ABOUT CHILDRENUsers in the United States

Except as described below, KingsIsle will not ask children under the age of 13 who register to use our Online Games and Services hereafter to submit any personal data. The only information requested from children under 13 will be a username and a user password. We may also ask such users to answer one or more security questions that do not request personal data. PLEASE NOTE: it is critical that users under the age of 13 retain their passwords because KingsIsle may not be able to reset the passwords when we have not collected a user or parental e-mail address.

If it becomes necessary to collect personal data from children under 13, KingsIsle will only do so after obtaining verifiable parental consent, as defined under COPPA, or as otherwise permitted under COPPA. For example, COPPA permits collection of personal data where (i) the sole purpose of collecting online contact information from a child is to respond directly on a one-time basis to a specific request from the child, and where such information is not used to re-contact the child or for any other purpose; (ii) the purpose of collecting a child’s and a parent’s name and online contact information is to protect the safety of a child; or (iii) KingsIsle collects online contact information of the child’s parent or guardian to obtain parental consent or to provide voluntary notice and/or updates to the parent or guardian about participation in our Online Games and Services.

On our Online Games and Services, we offer many features, such as the ability to view or download game content or images, news, or participate in forums, which do not require a child to provide any personal data. KingsIsle will not condition a child’s participation in any online activity on the child’s disclosure of more personal data than is reasonably necessary to participate in that activity. We also may enable users to chat online through our Online Games and Services, but we take measures to limit users’ ability to communicate personal data through this chat function.

Parental Review of Personal Data

In certain circumstances on some of our Online Games and Services, parents will have the ability to set up parental accounts to administer their children’s accounts and review the personally data maintained by KingsIsle from such accounts. Parents or guardians may establish a parental account during the initial registration process for the child’s account or, subsequently, through the account management features applicable to the child’s account. Although a child over the age of 13 may register without the electronic consent of a parent or guardian, a parent or guardian may also submit a request to KingsIsle at the contact information below to review any personally data from such child. However, such requests will be subject to the parent or guardian demonstrating proper identification to KingsIsle’s satisfaction after reasonable investigation

Users located in Europe

If you reside in Europe, you must be at least 16 years old to use our Online Games and Services. Our Online Games and Services are intended for general audiences and we do not knowingly collect any personal data from children in Europe under the age of 16. If it becomes necessary to collect personal data from children under 16 (in Europe), KingsIsle will only do so after obtaining verifiable parental consent or as otherwise permitted under applicable law. If you believe that a minor of whom you are a parent or guardian has provided us with personal data, please contact us at Privacy@KingsIsle.com and we will make reasonable efforts to remove all personal related to the minor.

CHOICES YOU HAVE ABOUT HOW KINGSISLE USES YOUR INFORMATION

You have the following choices regarding the personal data we collect or otherwise process about you:

You may send us an e-mail message at Privacy@KingsIsle.com to request access to review, correct or delete any personal data maintained on our systems that you or your child has provided to us through Online Games and Services registration process or other request. To protect your privacy, we will respond only to e-mail messages sent from the e-mail account that you specified (or was given by your child) during the account registration process.

You may also opt out of receiving newsletters and other promotional materials from KingsIsle by notifying us at Privacy@KingsIsle.com.

YOUR RIGHTS

You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified by KingsIsle or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the contact information provided in the " HOW YOU CAN CONTACT KINGSISLE" section above.

Access Right

You have the right to obtain confirmation as to whether or not your personal data is being processed by KingsIsle. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.

Right to Rectification

You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement.

Right to Erasure

You have the right to have your personal data erased where one of the following applies:

Your personal data is no longer necessary with regards to the purposes for which it was collected.

You withdraw your consent (where the processing is based on such consent).

You object to the processing where such processing is based on KingsIsle's (or a third party's) legitimate interest and there are no overriding legitimate grounds for the processing.

Your personal data must be erased in order to comply with a legal obligation under applicable law.

However, this right to erasure will not apply to the extent the processing is necessary for:

Compliance with a legal obligation which requires processing by applicable; or

Archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, to the extent permitted under applicable law.

Right to Restriction of Processing

You have the right to restrict the processing of your personal data where one of the following applies:

The accuracy of the personal data is contested.

The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead.

KingsIsle no longer needs the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims.

Where the processing is based on KingsIsle's (or a third party's) legitimate interest and you have objected to processing (as described below).

Right to Object

You have the right to object (on grounds relating to your particular situation) at any time to the processing of your personal data for direct marketing purposes or where the processing is based on KingsIsle's (or a third party's) legitimate interest. When objecting to processing based on our legitimate interest, KingsIsle will no longer process your personal data unless KingsIsle demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims.

Right to Withdraw Consent

Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.

Right to Data Portability

You have the right to receive your personal data, which you have provided to KingsIsle, in a structured, commonly used and machine-readable format, and have the right to transmit such data to another entity without hindrance from KingsIsle, where each of the following conditions are met:

The processing is based on your consent or the performance of a contract to which you are a party; and

The processing is carried out by automated means.

Right Not to Be Subject to Solely Automated Decisions

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.

Right to Submit a Complaint to Supervisory Authorities

You have the right to lodge a complaint with an applicable data protection authority. If you reside in Europe, you have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.

HOW KINGSISLE PROTECTS YOUR INFORMATION

We work hard to protect your personal data. We use both technical and procedural methods to maintain the integrity and security of our databases, including giving users a unique user name and password for access to our Online Games and Services, SSL encryption for data transfer, firewalls, and restricted access to data.

However, the safety and security of your information also depends on you. You should never share your password with anyone else and you should always logoff before leaving your computer or device. You should also use password security on your device itself. If you believe someone has unauthorized access to your password or account, please contact us promptly.

Our Online Games and Services may contain links to other websites operated by third parties that may be of interest to you (including links embedded in advertising appearing on components of our Online Games and Services or related applications). When you follow a link and leave our Online Games and Services, you do so at your own risk because we do not control such third-party websites.

RETAINING YOUR PERSONAL DATA

We generally retain personal data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain information for a longer period of time based on laws or regulations that apply to our business or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the original retention period.

CONSENT TO PROCESSING YOUR INFORMATION IN THE UNITED STATES AND ELSEWHERE

Our Online Games and Services are owned and operated by KingsIsle in the United States, but the information you provide will be accessible to our affiliates, vendors, and suppliers in other countries. Furthermore, if you are visiting our Online Games and Services from a country other than the United States, any information we collect or you provide will necessarily result in the transfer of information across international boundaries. The level of legal protection for such information is not the same in all countries; however, we will take the security measures described in this Privacy Statement in an effort to keep your information secure. By using our Online Games and Services, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations.

YOUR CHOICE TO EXCHANGE INFORMATION WITH OTHER USERS

Our Online Games and Services may also include forums, chat functionality or other features where you can exchange information or otherwise interact with other users of our Online Games and Services. When you do so, you understand that all information transmitted will be made available to and accessible by KingsIsle and applicable users. You have no expectation of privacy in connection with such communications. KingsIsle is not responsible for whether or how such third parties utilize the information you post or share through such features.

EFFECTIVE DATE; CHANGES

This Privacy Statement is effective as of July 19, 2018.

KingsIsle reserves the right to change its privacy policy in its sole discretion. In such case, KingsIsle will post the new Privacy Statement on Online Games and Services and the effective date of the new Privacy Statement will be clearly marked.